Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...
Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...
Income Tax : ITAT held that a return filed under section 148 remains valid even if delayed. Failure to issue mandatory notice under section 143...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : The Finance Bill 2026 proposes allowing taxpayers to file an Updated Return even after receiving a reassessment notice under Secti...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...
Income Tax : Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 14...
Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...
Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...
Income Tax : ITAT Indore held that appellate order violated principles of natural justice after finding that key hearing notices were sent to a...
Income Tax : Court ruled that reassessment notices under Section 148 must be issued through the faceless mechanism under Section 151A and the 2...
Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
Income Tax : The Jharkhand High Court held that retrospective insertion of Section 147A removed the jurisdictional challenge against reassessme...
Income Tax : The department has identified high-risk cases through its Insight Portal for AYs 2022-25. It directs officers to initiate reassess...
Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...
Income Tax : Explore the latest guidelines for issuing notice under Section 148 of the Income Tax Act, 1961. Understand key procedures, amendme...
Income Tax : Explore e-Verification Instruction No. 2 of 2024 from the Directorate of Income Tax (Systems). Detailed guidelines for AOs under I...
Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...
Madras High Court held that the provisions of section 153C of the Income Tax Act will not apply in case of initiation of search initiated on or after 01.04.2021. Accordingly, notices issued u/s. 153C are liable to be quashed and set aside.
The ITAT ruled that a Section 148 notice issued by a Jurisdictional AO after 29.03.2022 is invalid because, under the Faceless Reassessment Scheme, only the Faceless Assessing Officer can issue such notices. The entire reassessment was therefore quashed as without jurisdiction.
The ITAT held that the alleged bogus purchases could not stand when the assessee produced complete documentary evidence showing genuine procurement and consumption. With no contrary evidence from the AO, the 69C addition was removed.
The Tribunal held that once the 29.03.2022 Scheme came into force, only faceless units could issue such notices; a JAO-issued notice was illegal, nullifying the entire reassessment.
ITAT Chennai ruled that Section 148 notices issued manually by a Jurisdictional AO after 29.03.2022 violate the faceless reassessment procedure. The Tribunal quashed the reassessment order, emphasizing that only NFAC-issued notices are legally valid.
Arulmigu Vettudaiyar Kaliamman Thirukovil Vs ITO (ITAT Chennai) Assessee challenged reassessment solely on the legal ground that notices u/s 148 dated 31.03.2022 (AY 2015-16) & 29.03.2023 (AY 2016-17) were issued by the Jurisdictional AO (JAO) instead of the Faceless Unit, contrary to Sec.151A & CBDT’s Faceless Reassessment Scheme notified on 29.03.2022, which mandates automated/faceless issuance […]
ITAT Chennai held that a notice issued u/s 148 by the Jurisdictional AO after 29.03.2022 violates the mandatory faceless assessment scheme. Consequently, the reassessment and all subsequent actions, including penalty, were declared null and void.
The Revenue relied on third-party statements and WhatsApp data to allege an unrecorded ₹25 crore cash loan, but brought no supporting inquiry or cross-examination. The Tribunal held that the AO’s conclusion was speculative, especially when bank-backed evidence, TDS records, and a registered loan agreement supported only a ₹10 crore loan. Key takeaway: additions under Section 69A require concrete evidence, not assumptions.
ITAT clarifies that capital gains arise on the date of JDA execution, not registration, and allows reassessment if the agreement is cancelled before possession transfer.
Delhi High Court held that completed assessments cannot be disturbed without any incriminating material found during search. The Court dismissed Revenue’s appeal, reaffirming that additions under section 153A require evidence of undisclosed income or assets.
